`
`
`
`
`
`
`
`
`
`
`
`Case 1:19-cv-00859-RTH Document 69-2 Filed 01/21/22 Page 1 of 23
`
`IN THE UNITED STATES COURT OF FEDERAL CLAIMS
`
`
`
`
`
`
`E-NUMERATE SOLUTIONS, INC. and
`
`E-NUMERATE, LLC,
`
`C.A. No. 19-859-RTH
`
`Plaintiffs,
`
`v.
`
`
`
`
`
`THE UNITED STATES OF AMERICA,
`
`
`
`
`
`
`Defendant.
`
`PLAINTIFFS’ PRELIMINARY PROPOSED CLAIM
`CONSTRUCTIONS FOR TERMS IDENTIFIED BY
`THE DEFENDANT
`
`Pursuant to the Court’s Order of November 9, 2021 (D.I. 64), Plaintiffs e-Numerate
`
`Solutions, Inc. and e-Numerate, LLC (collectively “e-Numerate”) hereby provide the
`
`following preliminary proposed claim constructions for terms identified by the Defendant.
`
`Plaintiffs have previously provided to Defendant their preliminary claim constructions for
`
`terms identified by Plaintiffs. Those constructions are incorporated by reference as if fully
`
`set forth herein.
`
`Plaintiffs have sued Defendant for infringement of United States Patents 7,650,355
`
`(“the ‘355 patent”); 8,185,816 (“the ‘816 patent”); 9,262,383 (“the ‘383 patent”); 9,262,384
`
`(“the ‘384 patent”); 9,268,748 (“the ‘748 patent”); 9,600,842 (“the ‘842 patent”); 10,223,337
`
`(“the ‘337 patent”); and 10,423,708 (“the ‘708 patent”) (collectively, “the Asserted Patents”).
`
`Plaintiffs’ preliminary proposed claim constructions for terms identified by the Defendant in
`
`1
`
`
`
`
`
`
`
`Case 1:19-cv-00859-RTH Document 69-2 Filed 01/21/22 Page 2 of 23
`
`the Asserted Patents are set forth as Exhibit A.1
`
`e-Numerate reserves the right to add additional terms, omit terms specified below,
`
`and modify terms into phrases (and vice versa), including, but not limited to, in response to
`
`terms, phrases and proposed constructions identified by Defendant the United States of
`
`America (“the Defendant”). e-Numerate further reserves the right to modify, supplement,
`
`alter, delete and/or contradict any and all of these proposed constructions as this matter
`
`proceeds.
`
`
`
`
`
`Dated: November 19, 2021
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`/s/ Sean T. O’Kelly
`Sean T. O’Kelly
`Gerard M. O’Rourke
`O’KELLY & O’ROURKE, LLC
`824 N. Market Street, Suite 1001A
`Wilmington, DE 19801
`302-778-4000
`sokelly@okorlaw.com
`gorourke@okorlaw.com
`
`Attorneys for Plaintiffs
`
`
`1 Defendant claims that e-Numerate is not asserting claim 46 of the ‘355 patent, claim 19 of the
`‘816 patent, and claims 6, 14, and 15 of the ‘383 patent. Defendant is wrong. Claim 46 of the
`‘355 patent, claim 19 of the ‘816 patent and claims 6, 14 and 15 of the ‘383 patent are asserted in
`the Second Amended Complaint in this matter. See D.I. 53 at pars. 51, 65 and 82. In addition,
`infringement contentions for these claims were provided in Plaintiffs’ Second Supplemental
`Preliminary Infringement Contentions served on or about June 8, 2021. Defendant is referred to
`the following exhibits: Ex. A at page 48; Ex. B at page 32; and Ex. C at pages 22 and 24.
`2
`
`
`
`
`
`Case 1:19-cv-00859-RTH Document 69-2 Filed 01/21/22 Page 3 of 23
`Case 1:19-cv-00859-RTH Document 69-2 Filed 01/21/22 Page 3 of 23
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`EXHIBIT A
`EXHIBIT A
`
`3
`
`
`
`Case 1:19-cv-00859-RTH Document 69-2 Filed 01/21/22 Page 4 of 23
`
`‘355 Patent
`Term
`macro
`
`generating at least one
`second title
`corresponding to
`results of the operation
`interpreted code
`report
`at least one of… and
`
`the step of receiving
`
`Claims
`1, 2, 3, 4, 6, 25, 26,
`27, 28, 29, 30, 31,
`33, 52, 53, 54, 55
`1, 28
`
`1, 27, 28 and 54
`21
`7, 8, 9, 10, 11, 12,
`14, 21, 34, 35, 36,
`37, 38, 39, 41, 46,
`55
`15 and 42
`
`tag
`
`1, 13, 14, 15, 27, 28,
`40, 41, 42, 54
`
`
`
`
`
`Plaintiffs’ Proposed Construction
`Interpreted code that performs a well-defined, generally limited task
`
`Plain and ordinary meaning
`
`Code that is executed by an interpreter
`Plain and ordinary meaning
`At least one of … or
`
`Not indefinite. In claim 15, the step referred to is “receiving a series of numerical
`values having tags indicating characteristics of the numerical values” in claim 1. In
`claim 42, the step referred to is “receiving a series of numerical values having tags
`indicating characteristics of the numerical values” in claim 28.
`“Tag” should not be construed as a stand-alone term. Instead, Plaintiffs have
`identified a phrase that should be construed in claims 1, 27, 28 and 54. The
`Defendant is referred to that construction. To the extent “tag” is construed, it should
`be construed as “markup language tag.”
`
`4
`
`
`
`Case 1:19-cv-00859-RTH Document 69-2 Filed 01/21/22 Page 5 of 23
`
`
`
`meta-data
`
`numerical values
`having tags indicating
`characteristics of the
`numerical value “s”
`
`1, 13, 27, 28, 40 and
`54.
`1, 27, 28 and 54
`
`operation
`transform
`
`1, 27, 28 and 54
`1, 27, 28 and 54
`
`
`‘816 patent
`Term
`at least one of … and
`
`tag
`
`Claims
`1, 4, 10, 17, 20, 26,
`27
`1, 3 – 8, 10, 17 and
`19 – 27
`
`
`markup language
`
`12
`
`means for displaying the
`single data set
`
`26
`
`Data about data
`
`The Defendant has misquoted the claim language. Plaintiffs have previously
`proposed to include “series of” in addition to the specified language. Plaintiffs
`have previously provided their proposed construction of this phrase and the
`Defendant is referred to that construction. Additionally, Defendant omitted the “s”
`on the word “values.”
`Plain and ordinary meaning
`“Transform” should not be construed as a stand-alone term. Instead, Plaintiffs have
`identified a phrase in claims 1, 27, 28 and 54 that should be construed. The
`Defendant is referred to that construction. To the extent “transform” is construed,
`it should be construed as “convert.”
`
`Plaintiffs’ Proposed Construction
`At least one of … or
`
`“Tag” should not be construed as a stand-alone term. Instead, Plaintiffs have
`identified a phrase in claims 1, 10, 17, 26 and 27 that should be construed.
`Plaintiffs have previously provided their proposed construction of this phrase and
`the Defendant is referred to that construction. To the extent the term “tag” is
`construed, it should be construed as “markup language tag.”
`Not indefinite. Antecedent basis is implied, inter alia, by the use of the term
`“markup document” in claim 10. No additional construction of “markup
`language” is needed. To the extent “markup language” is construed, it should be
`construed as Plaintiffs propose for the ‘337 patent. The Defendant is referred to
`that construction.
`To be construed under § 112 par. 6.
`
`Function: displaying the single data set
`
`
`
`5
`
`
`
`Case 1:19-cv-00859-RTH Document 69-2 Filed 01/21/22 Page 6 of 23
`
`means for receiving a
`first markup document
`and a second
`markup document, both
`the first markup
`document and
`the second markup
`document containing
`numerical values
`and tags reflecting
`characteristics of the
`numerical
`values wherein the
`characteristics indicate
`that the
`numerical values of the
`first markup document
`differ in
`format from the
`numerical values of the
`second markup
`document
`
`means for automatically
`transforming the
`numerical values
`
`26
`
`26
`
`
`Structure: graphical user interface.
`Fig. 7A block 734; Figures 15 A, B & C; Fig. 19 B; col. 35, line 50 – 63; col. 36,
`line 66 – col. 37, line 45; col. 48, lines 41 – 49; col. 53, lines 44 – 53.
`
`To be construed under § 112 par. 6.
`
`Function: receiving a first markup document and a second markup document.
`
`Structure: Reader See, e.g., Fig. 7A box 704, Fig. 8, step 802, col. 8, line 4; col.
`19, lines 30 – 48; col. 29, lines 35 – 65; col. 30, lines 37 – 45.
`
`To be construed under § 112 par. 6.
`
`Function: for automatically transforming the numerical values
`of at least one of the first markup document and the
`second markup document
`
`
`
`6
`
`
`
`Case 1:19-cv-00859-RTH Document 69-2 Filed 01/21/22 Page 7 of 23
`
`Structure: X-value transformer employing conversion factors. Fig. 7A block 710;
`Figure 8 block 808; Figure 10, blocks 1012 and 1014; Figure 11; col. 19, line 49 –
`col. 20, line 3; col. 23, lines 47 – 59; col. 30, line 46 - col. 33, line 33; col. 25, line
`45 – col. 27, line 45.
`
`
`
`26
`
`1, 10, 17, 26, 27
`1, 10, 17, 26, 27
`
`1, 10, 17, 26, 27
`
`To be construed under § 112 par. 6.
`
`Function: means for combining the first markup document and the second markup
`document
`
`Structure: primary data store; Fig. 7, Box 712; Figure 8, line 810; Fig; 11; Figure
`13; col. 19, line 66 – col. 20, line 3; col. 31, lines 4 – 30; col. 33, lines 9 – 59; col.
`35, line 50 – col. 36, line 40.
`A document that contains markup language tags.
`Markup language tags wherein the markup language tags for the one or more
`numerical values have more than one attribute that explains the meaning of the
`numerical values
`
`One or more attributes for the numerical values in the first markup document are
`different from one or more attributes for the numerical values in the second
`markup document
`
`of at least one of the first
`markup document and
`the
`second markup
`document, so that the
`numerical values
`of the first markup
`document and the
`second markup
`document have a
`common format
`
`means for combining the
`first markup document
`and the
`second markup
`document into a single
`data
`
`
`markup document
`tags reflecting
`characteristics of the
`numerical values
`
`wherein the
`characteristics indicate
`that the numerical values
`of the first markup
`document differ in
`format from the
`numerical values of the
`
`
`
`7
`
`
`
`Case 1:19-cv-00859-RTH Document 69-2 Filed 01/21/22 Page 8 of 23
`
`second markup
`document
`
`transforming/transforms 1, 10, 17, 26, 27
`
`characteristic of the
`numerical value
`
`
`‘383 Patent
`Term
`rule
`data document
`line item
`presentation
`report
`tag
`
`semantic tag
`
`means for identifying a
`first markup document
`including
`
`
`
`“Transforming”/ “Transform” should not be construed as a stand-alone terms.
`Plaintiffs have previously proposed construing these terms and have provided a
`proposed construction for that phrase. The Defendant is referred to that
`construction. To the extent that “transforming” and “transforms” are construed,
`they should be construed as “converting” and “converts” respectively.
`An attribute that explains the meaning of the numerical value.
`
`27
`
`Plaintiffs’ Proposed Construction
`Claims
`Plain and ordinary meaning
`9, 10
`7, 8, 9, 10, 11, 12, 15 A markup language document that contains data
`7, 8, 15
`A set of data values that share metadata.
`14
`Plain and ordinary meaning
`14
`Plain and ordinary meaning
`1, 4, 17
`“Tag” should not be construed as a stand-alone term. Instead, Plaintiffs have
`identified a phrase in claims 1, 17 and 18 that should be construed. The Defendant
`is referred to that construction. To the extent that “tag” is construed, it should be
`construed as “markup language tag.”
`“Semantic tag” should not be construed as a stand-alone term. Instead, Plaintiffs
`have identified a phrase in claims in claims 1, 17, and 18 that should be construed
`and have provided a construction therefore. The Defendant is referred to
`Plaintiffs’ construction. There is no need to construe additional uses of the term
`in claims 6 – 8, 11, 12, and 15.
`To be construed under § 112 par. 6.
`
`Function: identifying a first markup document including first numerical values
`and first tags reflecting first characteristics of the first numerical values associated
`
`6-8, 11, 12, 15 and
`18.
`
`18
`
`8
`
`
`
`Case 1:19-cv-00859-RTH Document 69-2 Filed 01/21/22 Page 9 of 23
`
`with a first unit of measure, and a second markup document including second
`numerical values and second tags reflecting second characteristics of the second
`numerical values associated with a second unit of measure
`
`Structure: Reader See, e.g., Fig. 7A box 704, Fig. 8, step 802; col. 17, line 27 –
`col. 18, line 7; col. 28, lines 1 – 31; col. 29, lines 3 – 11.
`
`first numerical values
`and first tags reflecting
`first characteristics
`of the first numerical
`values associated with a
`first unit of measure,
`and a second markup
`document
`including second
`numerical values and
`second tags
`reflecting second
`characteristics of the
`second numerical
`values associated with a
`second unit of measure,
`wherein the first tags
`and the second tags
`each include computer-
`readable semantic tags
`that describe a semantic
`meaning of a
`corresponding one of at
`least one of the
`first numerical values
`or the second numerical
`values
`via a computer-readable
`tagging association
`therebetween, where
`the first characteristics
`of the first numerical
`
`
`
`9
`
`
`
`Case 1:19-cv-00859-RTH Document 69-2 Filed 01/21/22 Page 10 of 23
`
`values associated with
`the first unit of measure
`are
`different from the
`second characteristics
`of the second
`numerical values
`associated with the
`second unit of measure
`
`means for automatically
`transforming at least a
`portion of
`the first or second
`numerical values of at
`least one of the
`first markup document
`or the second markup
`document,
`so that at least some of
`the first numerical
`values of the
`first markup document
`and at least some of the
`second
`numerical values of the
`second markup
`document have a
`common unit of
`measure
`
`means for processing at
`least a part of the first
`
`
`
`18
`
`To be construed under § 112 par. 6.
`
`Function: automatically transforming at least a portion of the first or second
`numerical values of at least one of the first markup document or the second
`markup document
`
`Structure: X-value transformer employing conversion factors. Fig. 7A block 710;
`Figure 8 block 808; Figure 10, blocks 1012 and 1014; Figure 11; col. 18, lines 8 –
`30; col. 22, lines 17 – 29; col. 29, line 13 – col. 31, line 29; col. 24, line 9 – col. 26,
`line 10
`
`
`
`18
`
`To be construed under § 112 par. 6.
`
`
`10
`
`
`
`Case 1:19-cv-00859-RTH Document 69-2 Filed 01/21/22 Page 11 of 23
`
`markup document and
`at least a part of the
`second markup
`document,
`resulting in a single
`markup document
`
`means for causing a
`display of at least a
`portion of the
`single markup
`document
`
`18
`
`1, 17, 18
`
`1, 17, 18
`
`1, 17, 18
`
`1
`
`markup document
`
`first tags reflecting
`characteristics of the
`first numerical values
`
`second tags reflecting
`characteristics of the
`second numerical
`values
`
`wherein the first tags
`and the second tags
`each include computer-
`readable semantic tags
`that describe a semantic
`
`
`
`Function: processing at least a part of the first markup document and at least a part
`of the second markup document, resulting in a single markup document
`
`Structure: primary data store;
`Fig. 7, Box 712; Figure 8, line 810; Fig; 11; Figure 13; col. 18, lines 25 – 30; col.
`29, lines 37 – 63; col. 31, line 45 – col. 32, line 25.
`
`To be construed under § 112 par. 6.
`
`Function: causing a display of at least a portion of the single markup document
`
`Structure: graphical user interface.
`Fig. 7A block 734; Figs. 14 A – D, Figures 15 A, B & C; Fig. 16, Fig. 17, Fig. 19
`B; col. 34, line 13 – 26; col. 35, line 23 – col. 36, line 7; col. 46, line 65 – col. 47,
`line 6.
`
`
`A document that contains markup language tags
`
`Markup language tags wherein the markup language tags for the one or more
`numerical values have more than one attribute that explains the meaning of the
`numerical values
`
`Markup language tags wherein the markup language tags for the one or more
`numerical values have more than one attribute that explains the meaning of the
`numerical values
`
`Markup language tags wherein the markup language tags for the one or more
`numerical values have more than one attribute that explains the meaning of the
`numerical values
`
`11
`
`
`
`Case 1:19-cv-00859-RTH Document 69-2 Filed 01/21/22 Page 12 of 23
`
`meaning of a
`corresponding one of at
`least one of the first
`numerical values or the
`second numerical
`values
`transformation/
`transforming
`
`1, 17
`
`“Transformation” and “transforming” should not be construed as stand-alone
`terms. Plaintiffs have identified phrases including these terms that should be
`construed and proposed a construction therefore. The Defendant is referred to that
`construction. To the extent “transformation” and “transforming” are construed,
`they should be construed as “conversion” and “converting” respectively.
`
`
`
`12
`
`
`
`Case 1:19-cv-00859-RTH Document 69-2 Filed 01/21/22 Page 13 of 23
`
`7, 8 and 15
`
`multiple hierarchical
`relationships between
`two line items of
`corresponding
`numerical values
`
`As used in claims 7 and 15, Plaintiffs contend that the phrase should contain the
`word “includes” before “multiple” and should be construed as “includes a line item
`in various types of hierarchical relationships with other line items. By way of
`example, parent-child, siblings, grandparent - grandchild, etc.” Claim 8 uses the
`term “capable of”. Plaintiffs have previously provided a construction for the
`phrase including “capable of” and the Defendant is referred to that construction.
`
`7
`
`computer-readable
`semantic tags that
`describe a semantic
`meaning of one or more
`corresponding
`numerical values
`
`Defendant misquoted the claim language by omitting “each” and “of.” Plaintiffs
`have identified a phrase in claims 1, 17, and 18 that should be construed and have
`provided a construction therefore. The Defendant is referred to Plaintiffs’
`construction. There is no need to construe additional uses of the term in, for
`example, claim 7.
`
`
`
`13
`
`
`
`Case 1:19-cv-00859-RTH Document 69-2 Filed 01/21/22 Page 14 of 23
`
`8
`
`15
`
`Plaintiffs contend that “capable of including” should be construed as “may
`include” Plaintiffs have previously provided their constructions for the other
`phrases in this claim and the Defendant is referred to those constructions.
`
`Plaintiffs contend that “capable of including” should be construed as “may
`include.” Plaintiffs have previously provided their constructions for the other
`phrases in this claim and the Defendant is referred to those constructions.
`
`15
`17, 18
`
`Plain and ordinary meaning
`Plaintiffs have identified a phrase in claims 1, 17, and 18 that should be construed
`and have provided a construction therefore. The Defendant is referred to
`Plaintiffs’ construction.
`
`14
`
`capable of including at
`least one of: multiple
`hierarchical
`relationships between
`two line items of
`corresponding
`numerical values; or
`computer- readable
`semantic tags that each
`describe a semantic
`meaning of one or
`more of corresponding
`numerical values
`capable of including
`computer- readable
`semantic tags that each
`describe a semantic
`meaning of one or more
`of the corresponding
`values
`object
`computer- readable
`semantic tags that
`describe a semantic
`meaning of a
`corresponding one of at
`least one of the first
`numerical values or the
`second numerical
`values via a computer-
`readable tagging
`association
`therebetween
`
`
`
`
`
`Case 1:19-cv-00859-RTH Document 69-2 Filed 01/21/22 Page 15 of 23
`
`
`
`‘384 Patent
`Term
`data document
`line item
`presentation
`report
`semantic tag
`
`identify one or more
`indications
`for one or more of the
`original values for
`tagging, in
`connection with at least
`one computer-readable
`Extensible Markup
`Language (XML)-
`compliant data
`document, using a
`corresponding one or
`more computer
`readable semantic tags
`values
`data structure
`
`
`one or more computer
`readable semantic tags
`
`
`
`Claims
`66
`66
`66
`66
`66
`
`66
`
`66
`66
`
`66
`
`Plaintiffs’ Proposed Construction
`A markup language document that contains data
`A set of data values that share metadata.
`Plain and ordinary meaning
`Plain and ordinary meaning
`The term “semantic-tag” should not be construed as a stand-alone term. Plaintiffs
`have identified a phrase in claim 66 that should be construed and have provided a
`construction therefore. The Defendant is referred to Plaintiffs’ construction.
`Plain and ordinary meaning that incorporates Plaintiffs’ definition of “one or more
`computer readable semantic tags”
`
`Plain and ordinary meaning
`An organizational scheme that can be applied to data to facilitate interpreting the
`data or performing operations on it
`
`Plaintiffs have previously provided a construction for this phrase. The Defendant is
`referred to that construction.
`
`15
`
`
`
`Case 1:19-cv-00859-RTH Document 69-2 Filed 01/21/22 Page 16 of 23
`
`
`
`‘748 Patent
`Term
`rule
`data document
`
`line item
`
`presentation
`report
`multiple hierarchical
`relationships between
`two line items
`semantic tag
`
`Claims
`1, 12, 13 and 14.
`1, 10, 11, 12, 13, 14,
`20
`1, 4, 5, 11, 15, 16,
`19, 20
`11, 19, 20
`11, 19, 20
`1
`
`1 – 5, 11, 14 – 16,
`19, 20
`
`metadata
`code for storing a
`plurality of original
`documents including a
`plurality of original
`values, including a first
`document including
`first values and a
`second document
`including second values
`code for processing at
`least a part of the first
`document and at least a
`part of the second
`
`20
`11
`
`11
`
`
`
`Proposed Constructions
`Plain and ordinary meaning
`A markup language document that contains data
`
`A set of data values that share metadata.
`
`Plain and ordinary meaning
`Plain and ordinary meaning
`Plaintiffs have identified a phrase that includes “capable of including” in addition to
`this language and have provided a construction therefore. The Defendant is referred
`to that construction.
`“Semantic tag” should not be construed as a stand-alone term. Plaintiffs have
`proposed construction of phrases including this term for claims 1, 11 and 19. There
`is no need to construe the use of the phrase in claims 2- 5, 14 – 16 and 20.
`Data about data
`Not construed under § 112 par. 6. Terms should be construed consistent with other
`identified terms.
`
`Not construed under § 112 par. 6. Terms should be construed consistent with other
`identified terms.
`
`16
`
`
`
`Case 1:19-cv-00859-RTH Document 69-2 Filed 01/21/22 Page 17 of 23
`
`document, resulting in
`at least one object
`including at least one
`reference to at least one
`of the plurality of
`original values of at
`least one of the
`plurality of original
`documents
`code for receiving a
`user selection of one or
`more computer-
`readable semantic tags
`code for receiving a
`user selection of one or
`more of the original
`values
`code for mapping the
`one or more of the
`computer-readable
`semantic tags to the one
`or more of the original
`values
`code for outputting a
`presentation that is
`based on at least a
`portion of the at least
`one object, the
`presentation capable of
`including at least a
`portion of the original
`values including the at
`least one original value,
`
`11
`
`11
`
`11
`
`11
`
`Not construed under § 112 par. 6. Terms should be construed consistent with other
`identified terms.
`
`Not construed under § 112 par. 6. Terms should be construed consistent with other
`identified terms.
`
`Not construed under § 112 par. 6. Terms should be construed consistent with other
`identified terms.
`
`Defendant omitted this claim element. Not construed under § 112 par. 6. Terms
`should be construed consistent with other identified terms.
`
`
`
`17
`
`
`
`Case 1:19-cv-00859-RTH Document 69-2 Filed 01/21/22 Page 18 of 23
`
`where the computer
`program product is
`configured such that,
`based on the at least
`one reference of the at
`least one object to the
`at least one original
`value of the at least one
`original document, a
`change to the at least
`one original value of
`the at least one original
`document results in a
`corresponding change
`in an instance of the
`presentation
`code for outputting a
`report that is based on
`at least a portion of the
`at least one object, the
`report capable of
`including at least a
`portion of the original
`values including the at
`least one original value,
`where the computer
`program product is
`configured such that,
`based on the at least
`one reference of the at
`least one object to the
`at least one original
`value of the at least one
`
`
`
`11
`
`Not construed under § 112 par. 6. Terms should be construed consistent with other
`identified terms.
`
`18
`
`
`
`Case 1:19-cv-00859-RTH Document 69-2 Filed 01/21/22 Page 19 of 23
`
`11
`
`Not construed under § 112 par. 6. Terms should be construed consistent with other
`identified terms.
`
`19
`
`original document, a
`change to the at least
`one original value of
`the at least one original
`document results in a
`corresponding change
`in an instance of the
`report
`code for outputting at
`least one computer-
`readable Extensible
`Markup Language
`(XML)-compliant data
`document that is based
`on at least a portion of
`the at least one object
`and at least a portion of
`the mapping, the at
`least one computer-
`readable XML-
`compliant data
`document capable of
`including a plurality of
`line items with at least
`a portion of the original
`values including the at
`least one original value
`and at least some of the
`computer-readable
`semantic tags, where
`the computer program
`product is configured
`such that, based on the
`
`
`
`
`
`Case 1:19-cv-00859-RTH Document 69-2 Filed 01/21/22 Page 20 of 23
`
`at least one reference of
`the at least one object
`to the at least one
`original value of the at
`least one original
`document, a change to
`the at least one original
`value of the at least one
`original document
`results in a
`corresponding change
`in an instance of the at
`least one computer-
`readable XML-
`compliant data
`document:, said
`computer program
`product configured
`such that the at least
`some of the computer-
`readable semantic tags
`are each computer-
`readably coupled to the
`at least portion of the
`original values of at
`least one computer-
`readable XML-
`compliant data
`document
`data values/values
`capable of including
`multiple hierarchical
`
`1, 11 and 19
`1
`
`Plain and ordinary meaning
`May include a line item in various types of hierarchical relationships with other line
`items. By way of example, parent-child, siblings, grandparent - grandchild, etc.
`
`
`
`20
`
`
`
`Case 1:19-cv-00859-RTH Document 69-2 Filed 01/21/22 Page 21 of 23
`
`1, 11, 19
`
`Markup language tags for one or more data values that have more than one attribute
`that explains the meaning of the data values
`
`11 and 19
`
`Plain and ordinary meaning
`
`Plaintiffs’ Proposed Constructions
`Plain and ordinary meaning
`A markup language document that contains data
`A set of data values that share metadata.
`“Semantic tag” should not be construed as a stand-alone term. Plaintiffs have
`proposed construction of phrases including this term. The Defendant is referred to
`that construction.
`Plaintiffs have proposed a construction of this phrase including the words “capable of
`including”. Plaintiffs refer the Defendant to that construction.
`
`Plain and ordinary meaning.
`
`21
`
`relationships between
`two line items
`computer-readable
`semantic tags that
`describe a semantic
`meaning of the data
`values and are each
`computer-readably
`coupled to at least one
`of the data
`values/computer-
`readable semantic tags
`
`object
`
`
`
`
`‘842 Patent
`Term
`rule
`data document
`line item
`semantic tag
`
`Claims
`29
`29
`29
`29
`
`multiple hierarchical
`relationships between
`two of the plurality of
`line items
`data values
`
`29
`
`29
`
`
`
`
`
`Case 1:19-cv-00859-RTH Document 69-2 Filed 01/21/22 Page 22 of 23
`
`plurality of computer-
`readable semantic tags
`that describe a
`semantic meaning of
`the data values
`
`capable of including
`multiple hierarchical
`relationships between
`two of the plurality of
`line items
`
`
`‘337 Patent
`Term
`presentation
`data document
`report
`line item
`semantic tag
`
`29
`
`29
`
`Claims
`1
`1
`1
`1
`1
`
`values
`object
`computer-readable
`semantic tags
`markup language
`
`1
`1
`1
`
`1
`
`
`
`
`
`
`More than one markup language tags for one or more data values that have more than
`one attribute that explains the meaning of the data values
`
`May include a line item in various types of hierarchical relationships with other line
`items. By way of example, parent-child, siblings, grandparent - grandchild, etc.
`
`Plaintiffs’ Proposed Construction
`Plain and ordinary meaning
`A markup language document that contains data
`Plain and ordinary meaning
`A set of data values that share metadata.
`“Semantic tag” should not be construed as a stand-alone term. Plaintiffs have
`proposed construction of a phrase including this term. The Defendant is referred to
`that construction.
`Plain and ordinary meaning
`Plain and ordinary meaning
`Markup language tags for one or more values that have more than one attribute that
`explains the meaning of the values
`A markup language is a computer language that uses tags to define elements within a
`document. It is human-readable, meaning markup files contain standard words, rather
`than typical programming syntax. Examples of markup languages include HTML,
`XML and XBRL.
`
`22
`
`
`
`Case 1:19-cv-00859-RTH Document 69-2 Filed 01/21/22 Page 23 of 23
`
`Claims
`1, 10 and 17
`1, 10, 17
`1, 10, 17
`1, 10, 17
`1, 10, 17
`
`1, 10, 17
`
`1, 10, 17
`1, 10, 17
`
`Plaintiffs’ Proposed Construction
`Plain and ordinary meaning
`A markup language document that contains data
`A set of data values that share metadata.
`Plain and ordinary meaning
`“Semantic tag” should not be construed as a stand-alone term. Plaintiffs have
`proposed construction of a phrase including this term. The Defendant is referred to
`that construction.
`Plaintiffs have proposed a construction of this phrase including the words “capable of
`including”. Plaintiffs refer the Defendant to that construction.
`
`Plain and ordinary meaning
`Markup language tags for one or more data values that have more than one attribute
`that explains the meaning of the data values
`
`1, 10, 17
`
`May include a line item in various types of hierarchical relationships with other line
`items. By way of example, parent-child, siblings, grandparent-grandchild, etc.
`
`23
`
`‘708 Patent
`Term
`rule
`data document
`line item
`data values
`semantic tag
`
`multiple hierarchical
`relationships between
`two of the plurality of
`line items
`report
`computer-readable
`semantic tags that
`describe a semantic
`meaning of the data
`values
`
`capable of including
`multiple hierarchical
`relationships between
`two of the plurality of
`line items
`
`
`
`
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
